To prove that the defendant is guilty of this crime, the People
must prove that:
1. While driving a vehicle, the defendant knowingly caused
or participated in a vehicular collision;
2. When the defendant acted, (he/she) knew that the purpose
of the vehicular collision was to make a false or
fraudulent insurance claim for financial gain;
3. When the defendant acted, (he/she) did so with intent to
defraud;
AND
4. The collision caused the death of another person.
A person intends to defraud if he or she intends to deceive
another person in order to cause a loss of, or damage to, a legal,
financial, or property right.
[For the purpose of this instruction, a person includes (a
governmental agency/a corporation/a business/an association/the
body politic).]
[An act causes death if the death is the direct, natural, and
probable consequence of the act and the death would not have
happened without the act. A natural and probable consequence is
one that a reasonable person would know is likely to happen if
nothing unusual intervenes. In deciding whether a consequence is
natural and probable, consider all of the circumstances
established by the evidence.]
[There may be more than one cause of death. An act causes
death only if it is a substantial factor in causing the death. A
substantial factor is more than a trivial or remote factor.
However, it does not need to be the only factor that causes the
death.]